Penang Forum finds that the harm outweighs the benefits. Thus this Detailed EIA is NOT acceptable and should NOT be approved, says the civil society coalition.

This second media statement covers Penang Forum’s assessment of the loss of marine biology and fisheries and of the impact on traffic. We also provide a more realistic – and grim – cost-benefit analysis.

1. Impact on marine biology and fisheries

a) The DEIA is deficient and misleading in investigating and reporting on the impact of the STP2 project on the marine biology and fisheries in the area. The marine biology study was conducted at five sampling stations despite the undertaking made to the TOR Panel Review for the DEIA to increase the sampling coverage along extended transects and at multiple depths in the water. There is also no mention of sampling dates and frequency of sampling, given that occurrence and densities of mobile aquatic organisms can vary within a day and with season.

b) A map of fishing grounds shown repeatedly in the DEIA report is grossly misleading as it provides only a partial coverage of the fishing locations of the Tanjung Tokong fishers and omits altogether other fisher communities along the north coast i.e. Gurney Drive, Paramount and Tanjung Bungah.

c) The DEIA also under-estimates and under-values the project’s impact on fisheries while overstating the ease of mitigating this impact.

First, not enough detail is provided in the calculations for valuation of the direct use value of the mudflats for a proper check on the reported figures.

Second, computing the value of fisheries catch per hectare of mudflats based on the total mudflat area in Peninsular Malaysia is a gross under-estimation because not all mudflat areas are accessible and actively fished.

Third, the estimate of loss is done only for the 328ha of mudflat directly affected by the creation of the island and the reclamation along Gurney Drive but omits areas that will be off-limits to fishers during the five years of project implementation and after project completion.

Fourth, there are gross underestimations of losses to fishermen: e.g valuing shrimp at US$200/tonne when prices have already hit US$20/kg (or US$20,000/tonne) in February 2014.

Fifth, the DEIA valued the mudflats based on its direct use (i.e. direct harvest of seashells and shrimp) and wrongly equated this estimate with the total ecosystem service value. It has not considered a larger indirect use value of the mudflats as breeding and feeding grounds for many other fish species that are caught further offshore.

d) The DEIA does not cover the environmental impact of excavating 33.1 million m3 of sand (enough to form an island that is 85 per cent the size of Pulau Jerejak) from off the Perak coast, a mere 40km west of Pulau Pangkor, which is also an important fishing ground for Perak fishers. Hence there is a hidden value associated with off-site impact on the fisheries around and beyond the project site within Penang and Perak waters that adds to the gross under-estimation of the project’s impact on fisheries.

2. Impact on livelihood of fisher folk

The DEIA report is callous and equally dismissive in its treatment of affected fisher folk and birds in supposing that they can go seek new grounds to sustain their living. It conveniently transfers the responsibility for helping the fisher folk to other government organisations like LKIM and USM to seek new fishing grounds and aquaculture sites.

It is naive to suppose there are new fishing grounds when the entire inshore fishing area within reach of the affected artisanal fishermen is already over-fished. It is also equally naive to suggest that fishermen can be relocated to operate pond aquaculture in Sungai Pinang West and cage culture in the southern channel between Penang Island and Seberang Perai.

No costs – financial and social – are evaluated for displacing people who have lived all their lives in the north coast to areas already occupied by others to engage in livelihood activities that are totally alien to them. The only compensation suggested for the fishermen is for additional fuel costs for their boats to go further afield on their fishing trips. It is not even clear for how long this compensation will be provided, nor is there recognition of lost time and opportunity costs, as well as the possibility of reduced catch per unit effort.

3. Traffic impact assessment (note – NO consultant is named in the Report)

A survey carried out by the DEIA consultants showed that the most cited reason respondents disagree with the STP2 project is increased traffic congestion. The DEIA report estimates that STP2 will support more than 200,000 population. This will create massive pressure on the traffic dispersal and transport system in the project site and its neighbouring townships. A review of the traffic impact assessment of the DEIA report by members of Penang Forum and concerned Penangites raises several major concerns:

a) The traffic study carried out by the traffic consultants for Pulau Tikus, Jalan Kelawei and Jalan Burma was based on the old two-way traffic flow system. These roads have now changed to one-way and hence the results of the traffic study for these areas are no longer valid.

b) The consultants used peak 9,649 cars in the mornings and 12,134 cars in the evenings for 23,358 residential units. This works out to be less than 1/2 car equivalent per household for an affluent township! (The current Penang statistics show more vehicles than the Penang population.)

A recent TIA for a project in Sungai Nibong of 1,560 residential units with an estimated 5,470 residents puts peak morning traffic at 9,737 pcu/hr and peak evening at 11,362 pcu/hr. STP2 is 10 times bigger! How can a township of 200,000 people produce such an unrealistic traffic increase? When basic data used in the study are so questionable, the accuracy of the whole traffic impact assessment report is in question.

c) The DEIA report assumed that “by the time the proposed development is completed (by 2034), the public transport utilisation would already achieve 40 per cent”. On what basis did the consultants use this ‘wishful thinking’ assumption to determine their trip generation data? Even the Penang Master Transport Plan acknowledges that 25 per cent mode share for public transport is already a good achievement. The current public bus transport mode share is only 3 per cent.

d) The success of the traffic dispersal plan for STP2 relies heavily on the timely completion of all the four mega road and undersea tunnel projects. The consultants emphasised that “the Penang Outer Ring Road (Porr) and other major highways that were initially planned to improve the traffic conditions along Jalan Tanjung Bungah, Jalan Tanjung Tokong and Pulau Tikus are now necessary”. Porr is still needed to link these four new highways and tunnel to the STP2 arterial roads and 10 new interchanges will need to be constructed. All these require public funding. The DEIA consultants are presenting a ‘best case scenario’ with everything completed in time by 2034. What happens if all or some of these mega projects do not materialise? Porr was and remains a very controversial project. Additionally who funds the 10 new interchanges and Porr?

(The Paragon Development Experience – The Paragon project was approved on the assumption that both Porr and the monorail would be built to solve the traffic congestion. Neither was built; the resulting traffic chaos is self-evident. We cannot repeat this mistake again on a much bigger scale with STP2. Road networks must be built and be in place before any large projects are allowed to take off.)

e) Conclusion: Penang Forum finds that the traffic impact section of the DEIA report is highly flawed and NOT acceptable. We call for a new report to be done by an independent traffic consultant appointed by the Penang state government and not by the project proponents. We also call on the Penang state government to ensure that all road networks and infrastructure be built and be in place before any large projects are allowed to take off.

4. Economic rational and cost-benefit analysis

A project of such monumental proportion should have clear and strong rationale as to why it is needed. What are the benefits and the costs? Who stands to benefit most? Who ends up bearing the social, economic and environmental costs? What are the nett benefits to society?

a) Why is the project needed and who stands to benefit most? The Report says it is needed to relieve growth pressure and scarcity of land (Vol 2, 4-2). In fact, housing construction has been growing at more than twice the rate of population growth with excess in high-end properties. This project will not meet the affordable housing shortage. It is aimed at the top 1-2 per cent of the population, with prices in the millions. (Note, to get a RM1m loan, you must have a minimum RM20,000 monthly income.) “The up-market nature of STP2′s mixed development tends to favour the affluent. In the process, the locals would lose out” (Volume 1, page 39).

b) The cost-benefit analysis (CBA) as presented is inadequate as it is too narrowly focused only on quantifying the costs of loss of mangrove area, of seabed for macro benthos, of mudflats and seabed, and of fishing ground and ignores many other social, economic and environmental costs.

c) The Report underestimates the quantum of financial losses (RM33m-50m over 50 years) of the fisheries due to many questionable assumptions such as: the benthic communities will recover in three years after dredging; the fuel costs at RM1.42 per litre for the next 50 years. Also the impact on Perak fishing grounds is left out of the analysis.

d) Furthermore, the loss of income affects not only the fishermen but the general public. As fishing grounds are destroyed, the price of seafood hurts ordinary people. We cannot continue to import fish, given global overfishing and depleting fish stock. For food security reasons, the State MUST protect its own fishing grounds wherever possible.

e) Other major costs that are not quantified and for which the public has to bear are:

i) Environmental costs of further siltation. So far, STP1 has not been made to bear the cost of siltation of Gurney Drive even though the DID report identified the siltation as a result of STP1. The Report is unclear where the new siltation will occur though some figures were given with some areas silting up faster than others. No costs are provided for the remedial measures and who should bear the costs.

ii) Another major cost is the post dredging of the flushing channel. The Report expects the Penang state to maintain the post dredging of the channel every five years?! WHY? This is clearly not sustainable development. No estimates are provided. Based on the widely accepted “polluter pays principle”, the party that causes the environmental damage bears the costs. Why should the general public pay for the enjoyment of the few (e.g. estimated costs for dredging Penang Port – RM350m)?

iii) Another cost that the public will bear is the degradation of water quality from sediment dispersal. It cannot be assumed that the mitigation measures such as silt curtains would be effective. There is also no analysis and data on the faecal coliform bacteria that is the most serious known health hazard of bodily contact with the sea.

iv) The Report assumes massive improvements in transport infrastructure are required to accommodate the increased traffic flow. What are the costs and who should shoulder them?

v) The Report recognises the risks of project abandonment and says the developer should take mitigating steps to close down the project. But environmental degradation or destruction would already have occurred. No analysis is presented as to how much this would cost and how the developer would pay to compensate.

f) Finally, what aesthetic and painful losses do ordinary Penangnites have to suffer as our sea shores and views are gradually destroyed, our public access to beaches taken from us, our waters becoming polluted, our tree-lined roads choked and our quality of life steadily diminishing, all in the name of ‘development’.

5. Conclusion

– The Report under-estimates the financial costs of loss of fisheries.

– It also neglects to examine and quantify financial losses associated with other social, economic and environmental costs identified above.

– It illogically assumes the public will bear the burden of these costs. It is the duty of a government to ensure that negative externalities and costs generated in a project are borne by the responsible party and not passed on to the public, i.e., “the polluter pays principle” should apply.

– It is incumbent for the project proponent to properly quantify these costs and set up an adequate fund to meet these costs, failing which the project should be scaled down to an acceptable level or the “no build option” identified in the report (Vol 2, 6.3) should be considered.

– It is unacceptable that the cumulative costs that the public has to bear are so disproportionate to the private benefit enjoyed by a few. (The gross development value of the project has been estimated at RM25bn.)

The Penang Forum requests:

An urgent independent review of STP1

An open public forum to debate/clarify/review the DEIA.

Additional separate EIAs as required by DOE headquarters to be submitted before approval of this DEIA.